1) Hospital Base Pathology Group
2) Services are rendered at ABC Hospital. They also have specimens from another hospital (123 Hospital) sent to ABC to be processed.
3) One Pathologist Leaves
4) A Locum Tenens was hired to perform the work for the provider who left however; only for the work that comes from the other hospital (123 Hospital)
5) The Locum does not have hospital privileges at ABC Hospital and that is why specimens were instead shipped to AAA Hospital to be processed.
(Note: The Locum has his personal business at AAA hospital, but does not want this temporary work to be mixed into his business.)

Question:
a) Is this Locum arrangement even valid?
b) Can we use the Pathologist who left add Q6 modifier and bill under AAA Hospital location since that is where it’s being processed?

We have been told to use the ABC hospital location where the group is and Pathologist left from.. But I don’t think this is right. The Locum is not there working at that facility.

I tried finding this on the CMS manuals, but unable to find specific verbiage to support why it shouldn’t be done this way.

Thank you,
GZ